Facts
The Petitioner, Kho Kho Federation of India (KKFI), claiming to be the recognized National Sports Federation (NSF), sought directions against the Union of India to take action against Respondent No. 2, Kho Kho India (KKI).
Source reference: para. 3-4The Petitioner alleged that KKI was violating sports regulations by using the term "India" in its name and portraying itself as the official body for Kho Kho.
Source reference: para. 3The Petitioner argued that its recognition as an NSF, which lasted through 2025, should be deemed to continue into 2026 unless specifically revoked.
Source reference: para. 7Respondent No. 2 contended that it is the only organization with international recognition under the Olympic Movement and that its own application for NSF status for 2026 is currently pending consideration by the Union.
Source reference: para. 6The Petitioner had previously filed representations regarding this dispute with the Union of India on 15.01.2026 and 20.01.2026.
Source reference: para. 8Issues
Whether the use of the term "India" by Respondent No. 2 violates the National Sports Development Code, 2011, and the National Sports Governance Act, 2025
Source reference: para. 3-4Whether a recognized NSF’s status is deemed to continue into a new calendar year (2026) in the absence of a specific revocation
Source reference: para. 7Whether the Court should adjudicate on the merits of NSF recognition while representations are pending before the Union of India
Source reference: para. 8Law Applied
The Court referred to the National Sports Development Code, 2011 and the National Sports Governance Act, 2025, which govern the recognition of National Sports Federations and the authorized use of the term "India" by sports associations.
Source reference: para. 3-4The Court further noted the precedent set in Maharashtra Carrom Association v. Union of India & Anr. (2025:DHC:9515), wherein the Court restrained a non-recognized federation from using the expressions "India" or "Indian" in its name, logo, or competitions.
Source reference: para. 5Reasoning
The Court refrained from examining the substantive merits of the dispute regarding which entity should be recognized as the NSF for the year 2026.
Source reference: para. 8It observed that the Union of India is currently seized of the competing claims from both the Petitioner and Respondent No. 2.
Source reference: para. 6-7Since the Petitioner had already submitted a representation (15.01.2026) and a reminder (20.01.2026) to the Union of India which were still pending, the Court found it "apposite" to allow the executive to decide the matter first.
Source reference: para. 8By directing a time-bound disposal of these representations, the Court applied the principle of exhaustion of administrative remedies before judicial intervention, thereby connecting the statutory requirements of the Sports Code to the pending administrative process.
Source reference: para. 8Holding
The Court disposed of the petition without expressing an opinion on the merits of the case.
It directed the Union of India to decide the Petitioner’s representation dated 15.01.2026 and the reminder dated 20.01.2026 in accordance with the law within four weeks from the receipt of the order.
Source reference: para. 8All rights and contentions of the parties were left open.
Source reference: para. 10Original Court PDF
Kho Kho Federation Of IndiavsUnion Of India And Ors
Click to open original judgment
Original judgment, available to read, download and summarize on LawLens.in